A customer that operates a video poker game will require some extra attention. We would recommend monitoring the customer for compliance with the registration requirements and many other provisions in the Video Gaming Act, 230 ILCS 40/1 et seq. Further, note that the FFIEC’s 2005 “Money Laundering Threat Assessment” publication identified video poker games as susceptible to use by criminal money launderers — they “laundered money through video poker games by feeding illicit proceeds into the machines (one, five, and ten dollar bills) and then either after playing briefly or not at all, they pressed the ‘cash out’ button which generated a receipt that was redeemed for a casino check” (page 52, or page 66 of the .pdf file).
Are you aware of any risks (besides Regulation GG if applicable and BSA/AML considerations) in allowing a customer to open a video poker account?
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